Before the New York City Council Committee on
Environmental Protection

November 8, 2001

I
thank the Environmental Protection Committee for inviting me to testify at
Oversight Hearings on the Environmental Impacts on Lower Manhattan Due to the
Terrorist Attack on the WorldTradeCenter.Though I am Scientist in Residence at LehmanCollege, and an adjunct professor
at HunterCollege, I am testifying on my own
behalf, since I have not had time to clear any statement with CUNY.My background in this area stems from my
stint in the 1980s as the Department of Sanitation's specialist on emissions
from incinerators.I have also served on
a National Academy of Sciences committee on Health Effects of Waste
Incineration.

Before
I begin with my prepared remarks, I want to respond to something that was
brought up earlier.The Committee should
know that a gram of diesel particulate is not as dangerous as asbestos, dioxin,
PCB, or many other organic compounds and heavy metals, so even though we have a
lot of information about the carcinogenicity of this one
pollutant, we shouldn't lose sight of each and every one of the other name and
unnamed pollutants created by the incineration of everything in the WorldTradeCenter that we don't have lots of
information about.It's important to
note that many of the hazardous air pollutants (e.g., benzene, dioxin, PCB) are
carcinogenic and/or toxic in the parts per billion range,
and heavy metals and acid gases are toxic in the parts per million range.

There
are several issues of importance to the public in the way the City as well as
USEPA has handled air quality issues in lower Manhattan since Sept. 11.While
there has been universal praise for the Administration for its handling of the
disaster, most of those who have been exposed to the lingering emissions and
dust are worried or sick.The
environmental agencies protest that nothing is wrong because each individual
pollutant is below action levels most of the time.But it is clear that a large number of
pollutants are significantly elevated above background levels.I received an email from Dr. David Cleverly
of EPA that dioxin was 50 times normal background levels, but not as high as
actionable levels.Background levels
refer to what is loosely considered to be "normal" levels of any
given pollutant in the atmosphere.It is
assumed that most pollutants exist in "clean" air at trace quantities
(this might be parts per billion, parts per trillion, etc).But what does it mean if dioxin plus several
other toxic organic compounds, heavy metals, acids and particulate matter are
elevated or even many times background levels and borderline actionable?It seems likely that breathing air in which
many toxic or carcinogenic pollutants are borderline
actionable is worse for public health than breathing air in which only one
pollutant is borderline.Yet this is how
the standards are written.Is it
protective of public health to look at each pollutant one at a time, ignoring
the additive effects of inhaling a mixture?Are there synergistic interactions between some of these compounds that
increase the impacts further?Since ambient air standards are for
individual pollutants, it is imperative that research be done to assess the
impacts on public health of combinations of pollutants.Standards need to be rewritten as well to
assess the impacts of synergy.

This is a new type of air
pollution source, with characteristics of a crematorium, a solid waste
incinerator, an asbestos factory, and even an ash-spewing volcano.No emissions standards exist for this type of
source, though I am familiar with emissions standards for incinerators.Many of us remember the bitter battles
between Brooklyn residents and the City over the Brooklyn Navy Yard plant.The emissions from this plant would have been
controlled well over 90% for most pollutants, and yet we have an incinerator
downtown which continues to burn totally uncontrolled.The size of the WorldTradeCenter "plant" has been
many times the size of any incinerator, two months have passed, and we have
heard very little about a serious attempt to contain the emissions from the
site and put out the fires.Why aren't we discussing erecting a
temporary structure (dome) over the site, and installing incinerator emissions
controls to clean the air inside the dome?Initially, while recovery operations are briefly suspended, the fires
could be starved by injecting nitrogen.

Entrainment
of pollutant-laden fine dust is also occurring, as we heard, by loading debris
into trucks and barges.There are
standards for reducing entrainment of incinerator ash.These involve spraying water and containment
in leak-proof, covered trucks.Why
aren't we following those?

Air Quality Data has been
selectively shared with the public, leaving the public mistrustful.EPA initially listed only asbestos in air,
asbestos in dust and a gross measure of particulate matter in air.After several weeks passed, EPA added PCB and
lead.All told, this was maybe 20 pages
of information. Then, in a televised public forum (City Club forum), EPA said
that all of its data was online.I
subsequently learned that EPA had 900 pages of data, including a list of heavy
metals, dioxins and furans, acid gases, as well as those items listed.But EPA has demanded that people who want to
see the data come to the repository and look at it.I asked for an electronic copy.I was told I was the first one to ask for
it!But I was told that would not be
possible.How could this be, since the
data Surely exist on someone's computer? The Manhattan
Borough President's office was told it could have a copy, but that it had to
write a Freedom of Information request.As far as I know, that office still has not received the data and we
have been talking about getting this data to them for a week or so.It is just this kind of secretive behavior
that invites people who do go down
to view the full datasets, to quote data selectively.If the data were available in a spreadsheet,
then academic, environmental, and community institutions could have already
started studies.Those who want to
conduct analyses are still unable to do so.

I'll
close by drawing an analogy with the way the environmental agencies are dealing
with the public health hazard downtown.In south Florida, where I grew up, in the
1940s, as tourism was quickly growing, the government kept information about
hurricanes secret for fear that too much information would hurt business,
particularly the tourist trade.Predictably, south Florida got walloped a couple of times, and then the
government, wisely, decided to make an about-face and become the world's
experts on hurricane tracking, prediction, alerts, and mitigation.They established a world-class center in Coral Gables to serve as the source of
information and research.Later, by the
time I was six, I was tracking every hurricane's progress on a chart I got for
free at the 7-11 store by listening to the radio for coordinates.

We
have exactly the same situation here.There is a lot we don't know.The
government wants to protect business and the tourist trade.The government has kept a great deal of
information off limits to anyone for the first several weeks, and lately it has
made it difficult to obtain in any usable form.Even worse than this is that we don't know the long-lasting impacts of
the initial huge, dense dust cloud on those running in its midst.We don't know the additive and synergistic
effects of many toxic and carcinogenic pollutants that continue to be emitted
from the fires or entrained from the dust as it blows off the rooftops and
ledges. Will these compromise immune systems, making them vulnerable to future
attacks?Now is a time for the environmental agencies to pull their heads from
the sand, make an about-face, release all data and
interpretive guidelines on the Web.The
Council should assist by committing City funds and encouraging the
Administration to seek federal 9/11 grants to conduct ongoing, comprehensive
surveillance of symptoms in affected populations, buy filters for residents,
pay for proper cleanup, research the acute and long-term impacts on health of
highly concentrated combinations of pollutants acting for a short time, as well
as elevated levels of combinations acting for longer periods of time.The government should write new standards to
reflect short-term exposure to high concentrations as well as synergistic
effects.I know that the City is loathe
to write its own pollution standards, preferring to rely on federal, but in
some cases we have acted, and this is clearly one of them.We need to have more contingency planning for
different types of environmental disasters as this new war against terrorism
progresses.This is the only way to
regain public trust. Recalling the hurricane example, and realizing that we may
not be finished with terrorism, becoming the world's experts in environmental
health disasters and being truly open with the public is the best course of
action in the long term.